managing flood risk through effective stakeholder engageme....2 managing flood risk through...

Joint Defra / Environment Agency Flood and Coastal ErosionRisk Management R&D Programme

effective stakeholder engagement

R&D Technical Report SC040033/SR4

Product Code: SCHO0905BJQT-E-P

Managing flood risk through

A scoping study on the Aire & Calder

Managing flood risk through effective stakeholder engagement2

Published by:Environment Agency, Rio House, Waterside Drive, Aztec West,Almondsbury, Bristol, BS32 4UDTel: 01454 624400 Fax: 01454 624409www.environment-agency.gov.uk

ISBN: 1844325059

© Environment Agency August 2005

All rights reserved. This document may be reproduced with priorpermission of the Environment Agency.

The views expressed in this document are not necessarilythose of the Environment Agency.

This report is printed on Cyclus Print, a 100% recycled stock,which is 100% post consumer waste and is totally chlorine free.Water used is treated and in most cases returned to source inbetter condition than removed.

Further copies of this report are available from:The Environment Agency’s National Customer Contact Centre byemailing [email protected] or bytelephoning 08708 506506.

Authors:Wilkinson, D and Wade, D

Dissemination Status:Publicly available

Keywords:Catchment flood management plans, Aire & Calder,stakeholder involvement, partnership-based approaches,implementation, flood risk management, Making Space ForWater, Water Framework Directive

Research Contractor:Whole Systems Development, Arncliffe, St Mary's Road,Riddlesden, Keighley, W Yorkshire BD20 5PATel: 01535 680537

Environment Agency’s Project Manager:Dr John Colvin, Social Policy Manager, Rio House, WatersideDrive, Aztec West, Almondsbury, BRISTOL BS32 4UD

Science Project Number:SC040033/SR4

Product Code:SCHO0905BJQT-E-P

The Environment Agency is the leading public body protecting andimproving the environment in England and Wales.

It’s our job to make sure that air, land and water are looked after byeveryone in today’s society, so that tomorrow’s generations inherit acleaner, healthier world.

Our work includes tackling flooding and pollution incidents, reducingindustry’s impacts on the environment, cleaning up rivers, coastalwaters and contaminated land, and improving wildlife habitats.

This report is the result of research commissioned and funded by theEnvironment Agency’s Science Programme.

Science at the Environment AgencyScience underpins the work of the Environment Agency. It provides an up-to-dateunderstanding of the world about us and helps us to develop monitoring tools andtechniques to manage our environment as efficiently and effectively as possible.

The work of the Environment Agency’s Science Group is a key ingredient in thepartnership between research, policy and operations that enables the EnvironmentAgency to protect and restore our environment.

The science programme focuses on five main areas of activity:

• Setting the agenda, by identifying where strategic science can inform our evidence-based policies, advisory and regulatory roles;

• Funding science, by supporting programmes, projects and people in response tolong-term strategic needs, medium-term policy priorities and shorter-term operationalrequirements;

• Managing science, by ensuring that our programmes and projects are fit for purposeand executed according to international scientific standards;

• Carrying out science, by undertaking research – either by contracting it out toresearch organisations and consultancies or by doing it ourselves;

• Delivering information, advice, tools and techniques, by making appropriateproducts available to our policy and operations staff.

Steve Killeen

Head of Science

Managing flood risk through effective stakeholder engagement 3t


Executive summaryThe overall objective of this Scoping Study was to establish the most appropriate andrealistic ways of engaging with stakeholders in the development of strategic CatchmentFlood Management Plans (CFMPs) for the Aire and the Calder. It sought to understandthis within the wider policy context of flood risk management.

The study found that many significant stakeholders along the Aire and Calder were notclear about the purpose of CFMPs and how they could relate to them. Many expressedthe hope that CFMPs would be the basis for inter-organisational partnership working onintegrated, holistic, long-term catchment plans for water management as a whole andflooding of all types. This was linked to the approaches expressed in Defra’s MakingSpace for Water. But stakeholders feared that CFMPs were much more narrowly focusedon improving hard defences on main river courses and that consultation withstakeholders was little more than a box-ticking exercise that the Environment Agencyhad to do. In short, they felt that CFMPs might be little more than old wine in new bottles.

The study also found that this external confusion about the overall direction of the CFMPphilosophy, approach and process was reflected to a degree within the EnvironmentAgency itself. Despite these uncertainties, personal relationships at the area levelbetween Environment Agency staff and stakeholders were good.

The report makes the following recommendations:

• There needs to be a single agreed narrative about what CFMPs are, and who andwhat they are for. This needs to embrace clearly the philosophy and approachexpressed in Defra policy in Making Space for Water. It also needs to explain thelinks to the Water Framework Directive River Basin Planning process and to otherland use plans. The River Teign Model Plan offers a starting point for this.

• This narrative needs to be brief and written in clear, accessible English.

• The Environment Agency should seek to build partnership relationships withstakeholders as early as possible in the CFMP processes for each catchment. Thisshould start with shared dialogue between all stakeholders about the purpose androle of CFMPs and the appropriate relationships needed for their development,implementation and renewal. This would recognise the appropriate types ofrelationship required at different times and for different purposes – clarifying where,for example, partnership, consultation and information giving may each be mostappropriate.

• Through this approach the Environment Agency would be seeking to clarify itsrelationships with other stakeholders in the overall CFMP process, but would alsobe encouraging them to develop their own partnership relationships with eachother.

• This Scoping Study should be followed by a Main Study to act as a demonstrationproject for the development of the approach above. The proposals outlined in thisreport include two linked streams for this work: the development of participatory

Managing flood risk through effective stakeholder engagement 5

stakeholder events and the establishment of learning frameworks both laterally andhierarchically within and beyond the Environment Agency. These are suggested asthe means of spreading learning and good practice as rapidly as possible within theEnvironment Agency.

• The Scoping Study findings suggest that early partnership building withstakeholders at the start of the CFMP process would both improve and speed upthe process, increase the extent of feedback, and increase stakeholders’ ownershipof the process. It would also lay the foundation for improving the implementation ofholistic, catchment-wide water management and managing flood risk of all types.

• The lessons learned from both this Scoping Study and the first half of theMain/Demonstration Study of the Aire and Calder could then be applied from thestart of the Don and the Hull CFMPs in 2006. The aim would be to improve,streamline and speed up both the CFMP process and its future implementation.


Contents1 Introduction...........................................................................................................71.1 Project objectives ...................................................................................................71.2 Framing the research .............................................................................................7

2 The policy context ................................................................................................92.1 Policy guidance ......................................................................................................92.2 Lessons learned from the pilot phase...................................................................102.3 System pressures that may limit strategic, holistic, partnership-based approaches

.............................................................................................................................102.4 Research and guidance on stakeholder engagement .......................................... 11

3 Stakeholder engagement in the Aire and Calder CFMP process....................123.1 What has been done so far ..................................................................................123.2 The methods used to elicit stakeholders’ views and expectations about

involvement in the CFMPs....................................................................................133.3 Stakeholders’ views and expectations about involvement in the CFMPs..............15

4 Overcoming barriers to effectiveness ..............................................................184.1 Overcoming barriers .............................................................................................184.2 Developing perceptions of the bigger picture........................................................204.3 Streamlining and speeding up the CFMP process................................................214.4 River Teign CFMP – Model Plan...........................................................................21

5 Proposals for the Main Study ............................................................................235.1 Developing participatory events............................................................................235.2 Developing learning frameworks ..........................................................................24

References.....................................................................................................................26

Appendix 1. North East, Ridings CFMPs timetable ....................................................28

Appendix 2. CFMP Regional Steering Group (Yorks and Humber) June 2005.........30

Appendix 3. Stakeholder feedback ..............................................................................33

Appendix 4. Aire and Calder CFMPs – list of people consulted over questionnaires........................................................................................................................................42

Appendix 5. The questionnaire ....................................................................................44


1 Introduction1.1 Project objectivesThe overall objective of this Scoping Study was to establish the most appropriate andrealistic ways of engaging with stakeholders in the development of strategic CatchmentFlood Management Plans (CFMPs) for the Aire and the Calder. The study wasundertaken by a small research team1 from the consultancy Whole SystemsDevelopment working alongside the Ridings Area Flood Defence Team and theEnvironment Agency’s Corporate Affairs team in the North East Region.

Initially there were five interlinking research themes or questions to this study:

1. How do the policy guidance, processes and procedures under which CFMPs areproduced set the context for stakeholder engagement?

2. What are the potential benefits or otherwise of engagement from the perspectivesof different stakeholders?

3. What is the potential for developing ‘catchment consciousness’ across allstakeholders, including those within the Environment Agency, as a basis forstrengthening and beginning to integrate flood risk with land use managementplans?

4. What can be learned from the experience of the CFMP pilots?

5. What is the potential and value of developing a learning process and frameworkfor the Ridings Area Flood Defence Team and others in the Environment Agency,linked to the development of CFMPs?

1.2 Framing the researchOur initial assumption was that understanding the decision-making process through theCFMP process would be vital to understanding how stakeholders could engage. Forinstance, do the procedures and tools used in modelling, generating scenarios andappraising options limit or even preclude stakeholder influence? Additionally, could thecomplexity of the analyses and tools involved be made sufficiently accessible and visualto enable stakeholders to obtain meaningful understanding as a basis for influencing?

However, during the study it became clear through the work on research theme two that‘understanding the potential benefits, or otherwise, from the different stakeholders’perspectives’ is the initial key to gaining real involvement from many significantstakeholders. In fact, it was establishing our own personal rapport with individualstakeholders that enabled us to get both substantial feedback and an enthusiasticinterest in the project. This has indicated to us that there is a prior set of questions thatneed to be addressed between the Environment Agency and stakeholders such as:

1 David Wilkinson and Diane Wade.


• Are CFMPs really about mitigating flood risk of all types across wholecatchments?

• Where does the philosophy and approach of Making Space for Water (Defra,2004) sit in relation to CFMPs?

• What are CFMPs for and who are they for?• Are they in reality the Environment Agency’s plans for hard defences on main

rivers?

If the Environment Agency is seeking a new holistic, catchment-wide approach, then thisneeds to be clarified and used as the basis for new levels of involvement. At this point,the questions raised above in relation to research theme one become highly relevant andremain largely outstanding.

As a result of these insights, over half the time allocated to this project was spent on thesecond research theme described above. Much of the rest was spent on the firstresearch theme, which sets the context for stakeholder engagement.

There is little doubt that there is an increasing ‘catchment consciousness’ among keystakeholders (research theme three). This was expressed through the need to addressflooding of all types through active partnerships embracing holistic and preventativemeasures. An unambiguous embracing of Making Space for Water, for example, wouldsupport this considerably. Essentially the development of ‘catchment consciousness’ isabout building shared mental models of the big catchment-wide picture that guide bothjoint and separate working. We believe that this would be an important theme in thedevelopment of any future Main Study. It would link directly to the need to develop morevisual models to enable people to see in broad perspective how whole rivers andcatchments ‘work’ (see section 5.1.2 below).

It is not at all clear to us what has been learned from the earlier CFMP pilots (theme four)or how this learning has been used in relation to the focus of this study. Section 2 makesreference to this.

During this project we have made a modest start on theme five, the development of alearning process. Sections 4 and 5 outline how this could be developed andstrengthened.

The structure of this report is organised on the basis of what appear to be the key issuesas they have emerged through the study. The section headings are:

2. The policy context3. Stakeholder engagement in the Aire and Calder CFMP process4. Overcoming barriers to effectiveness5. Proposals for the Main Study

The Ridings Area Flood Defence Team and Environment Agency regional CorporateAffairs staff have given strong and enthusiastic support to our work. The project has beenassisted hugely by them and we are very grateful for this.


2 The policy context2.1 Policy guidanceVolume 1: Policy Guidance on CFMPs (Defra and the Environment Agency July 2004)includes the following statements:

‘Catchment Flood Management Plans (CFMPs) are a planning tool through whichthe Agency aims to work in partnership with other key decision makers within ariver catchment to explore and define long-term sustainable policies for flood riskmanagement. CFMPs are a learning process to support an integrated approach toland use planning and management, and also River Basin Management Plansunder the Water Framework Directive.’ (Preface)

‘[A CFMP] … is a high-level strategic planning tool through which the EnvironmentAgency will seek to work with other key decision makers within a river catchmentto identify and agree policies for sustainable flood risk management.’ (p. 1)

‘CFMPs will identify broad policies for sustainable flood risk management thatmake sense in the context of the whole catchment and for the long term (50 to100 years). They will not determine specific flood risk reduction measures ormanagement approach for flooding issues in a catchment. While it is not possibleto understand in detail what will occur in 50 to 100 years time, general trends canbe projected to test the sustainability of plans. CFMPs will be reviewed asappropriate to reflect changes in the catchment, although this is unlikely to bewithin 5 years of the CFMP being produced.’ (p. 2)

‘The key objective of a CFMP is to develop complementary policies for long-termmanagement of flood risk within the catchment that take into account the likelyimpacts of changes in climate, the effects of land use and land management,deliver multiple benefits and contribute towards sustainable development.’ (p. 3)

‘Reducing flood risk calls for collaboration with local planning authorities,landowners, local communities and other interested groups. Hence theEnvironment Agency will seek to develop CFMPs in partnership with other flooddefence/land draining operating authorities, English Nature and Regional PlanningBoards, the Welsh Assembly, and in consultation with key stakeholders and thegeneral public.’ (p. 6)

Great emphasis is placed on developing the links between CFMPs and the widerplanning framework within this partnership approach (see pp. 6–8).

Given the above, there can be little doubting of the initial high-level strategic andpartnership approach being sought. Or is there?

Our findings from this study suggest that there are a number of systemic factors thatpush CFMPs in a rather less strategic and partnership-based direction. Stakeholderfeedback also indicates this (see section 3).


2.2 Lessons learned from the pilot phaseA presentation (2003) by Linda Aucott, Head of the Engineering Policy FloodManagement Division, Defra, on lessons from the pilot phase (taken from undated copy)noted that plans:

• were not sufficiently strategic;• had not sufficiently engaged key end users and this resulted in a lack of credibility

and fitness for purpose.

The proposed remedies that were suggested included revision of Volume 1 guidance,training in strategic thinking for key staff and improved project management. We are notin a position to know the result of these suggestions if any. But our meetings andinterviews with Environment Agency staff suggest a number of systemic pressures thatpush CFMPs in a much more limited and technocratic direction. They are systemic in thatthey are a product of the way the Environment Agency and Defra currently operate ratherthan being shortcomings in training and management or the fault of individual staffmembers. This is not to say that training and project management could not be improved,but, so far as we can say for the Aire and Calder CFMP process, they are not the primaryissues.

2.3 System pressures that may limit strategic, holistic,partnership-based approaches

The comments listed below are based on our reading of key guidance and modellingdocuments, plus meetings and conversations with Environment Agency staff at all levelsand consulting engineers. They are not categorical assertions, rather they are initialtentative propositions for further discussion.

• Despite the high-level policy intentions, most of the guidance is technical anddetailed. This is especially so when it relates to modelling (e.g. the ModellingDecision Support Framework (MDSF) itself, which is still in the process ofdevelopment).

• Even with this level of guidance there appears to be doubt about what a ‘good’CFMP should look like. (During our study, there was speculation about a CFMPtemplate being produced and what further guidance this would give. We gotaccess to it late in the study period. Its potential contribution is discussed insection 4.4).

• There is uncertainty about the relationship between the CFMP process, MakingSpace for Water and the Water Framework Directive despite the quote above fromthe Preface of Volume 1: Policy Guidance. One view is that Making Space forWater – during its development – has helped shape Volumes 1 and 2 guidance.Another is that it has come into the frame after the issuing of the guidance.

• Defra targets prioritise ‘no loss of life’ together with placing a strong emphasis ofeconomic value of property damage. These, together with short-term politicalpressures (main river floods are usually more high profile), a large increase in the


funding for flood defence and pressures from the insurance industry, serve to puta strong emphasis on hard defences on main rivers.

• The writing of guidance and the development of modelling and appraisal toolsappears to be largely done by external engineering consultancies who may havelittle experience of partnership working and the range of methodologies and skillsfor doing this.

• On the Aire and the Calder, all the CFMP development work is outsourced toengineering consultancies. The focus seems to be on getting (a largelytechnocratic) job done (i.e. the production of the plan as an end in itself ratherthan an emphasis on the long-term strategies and partnership building). Theresponsibility for stakeholder communication is rightly held within the EnvironmentAgency. However, as it stands, this seems an unfortunate split because it may beallowing external consultancies to disengage from their own partnershipresponsibilities. We do not know what the contractual arrangements andexpectations are around this.

• From our vantage point at area level, the Environment Agency appears veryhierarchical and top-down. But the ‘top-down’ approach appears more in the formof screeds of written guidance rather than visible support to clarify key policyissues and remove obstacles. Also, the contracting process for outsourcing theCFMP contracts is apparently held at regional level, as are the CFMP governanceframeworks. This is the context in which our core team, who are doing the internalwork, are operating. It is they who largely represent and ‘are’ the EnvironmentAgency to the stakeholders we have been in contact with.

2.4 Research and guidance on stakeholder engagementThe Environment Agency has developed a range of research studies and guidance insupport of stakeholder engagement. These include:

• the raft of research projects the Environment Agency has done on stakeholderengagement;2

• the (generic) Agency Management System (AMS) guidance on stakeholderengagement and its adaptation for Water Management communications;

• the Building Trust with Communities toolkit (Environment Agency 2004);• the CFMP communications blueprint (derived from CFMP policy guidance

volume 2).

These provide a good basis for the development of further guidance frameworks formore fully developed partnership working on CFMPs and Making Space for Water.

2 These include Downs (1997); Environment Agency (1998); Petts and Leach (2000); Twigger-Ross and Smith

(2000); Clark et al. (2001); Environment Agency (2003); Warburton (2004); Barnett et al. (2005); Orr and Pound(2005); Porter et al. (2005); Warburton et al. (2005).


3 Stakeholder engagement in the Aireand Calder CFMP process

3.1 What has been done so farAppendix 1 indicates the key milestones and outputs achieved so far and those plannedfor the future, for both the Calder and the Aire CFMPs. The following summarises whathas been done to date that relates specifically to stakeholder engagement for each of thetwo rivers.

3.1.1 Regional Steering Group

A Regional Steering Group for the Yorkshire and Humber Region has been set up toensure consistency across all the Environment Agency’s CFMPs and to raise awarenessof significant social, economic and environmental issues within the region.3 It has a rolein balancing the needs of stakeholders, providing guidance on policy development andconsidering the high-level impacts of proposed policies. The Regional Steering Groupreviews, comments on and endorses the Draft Plan and Final CFMP. Its members willaim to support the flood management policies once adopted.

3.1.2 The River Calder

Over recent years there has been a series of consultations in the catchment on variousstrategies and flood defence schemes. From 2001 these are: The Upper Calderpreliminary strategic review, the Ings Beck pre-feasibility study, the Wakefield flooddefence scheme and the Todmorden flood defence scheme. The first was undertakenthrough a combination of written communication and meetings with major groups; thesecond also included regular newsletters sent to the people at risk of flooding from IngsBeck. The latter two schemes are now being built and the communication has includedopen days and surgeries with Environment Agency staff and direct mailings to theresidents affected.

There is a communication plan for the Calder CFMP produced in line with nationalguidance on communication strategies for CFMPs. This sets out the context, objectivesand key messages. The latter states that:

‘The CFMP is a major step towards integrated catchment management bysupporting the implementation of the new Water Framework Directive by taking anintegrated, long-term approach to flood risk management at the catchment scale.’

The communication plan also lists categories of stakeholders, together with acomprehensive schedule of communications through the various project stages.

Consultations on the CFMP have been undertaken through a combination of writtencommunications and meetings. A workshop was held to discuss the findings from the

3 Membership of the Regional Steering Group is shown in Appendix 2.


Calder CFMP Inception Report. Written communication and a meeting on the draftScoping Report were carried out with the Regional Steering Group. There has beenconsultation following the publication of the Calder CFMP Consultation Report – ScopingPhase and the Calder CFMP Scoping Report. Both of these were through mailedcommunication.

3.1.3 The River Aire

Over recent years there has been a series of consultations on various reviews anddefence strategies. From 2001 these are: The Upper Aire preliminary strategic review,the Skipton stage 2 study, the Lower Aire villages south – village barrier banks study, theLower Aire preliminary strategic review and the Knottingley flood alleviation scheme.These consultations have been undertaken through a combination of writtencommunication and meetings. The Knottingley scheme has now been built and thecommunication had included open days and surgeries with Environment Agency staffand direct mailings to the residents affected.

There is also a communication plan for the Aire CFMP. There has been consultationfollowing the publication of the Aire Fact File and Aire CFMP Inception Report. Both ofthese were through mailed communication.

A Scoping Workshop was held on 6 April 2005 to review draft catchment appraisalobjectives and opportunities and constraints. Ten people from outside the EnvironmentAgency from eight different organisations attended this. A total of 21 organisations werecontacted to discuss the findings of the draft Aire CFMP Scoping Report on 21 June2005.

3.1.4 Overview

Our impression is that considerable thought and effort has been put into building upcomprehensive lists of stakeholders and contact points, sending communications to themand setting up meetings. We have no way of judging this, but it seems likely that thisconsultation effort, and what has been done and achieved so far, is comparable with thebest that is being done across the Environment Agency on CFMPs.

3.2 The methods used to elicit stakeholders’ views andexpectations about involvement in the CFMPs

3.2.1 The methods of inquiry used

We have researched stakeholder views through a mix of face-to-face and telephoneinterviews. In addition, we designed a questionnaire in consultation with the core team.The core team consisted of David Wilkes (Ridings Area Flood Defence Manager), IainAndrews (Strategic Planning Team Leader), Sophie Vanicat (Flood Defence StrategicPlanning Engineer), Lara Dalton (Communications Manager) and Jayne Hoole(Communications Officer). The intention was to use the questionnaire as an adjunct toeither telephone or face-to-face interviews where possible. For the most part, they weredistributed by email. We found that where we have established a personal link withindividuals, and they have been able to make sense of our intentions and remit, they


have been willing to make time for lengthy phone calls or meetings. On the other hand,sending the brief and the questionnaire without this follow-through contact has producedlittle response. For significant organisations like local authorities it seems particularlyimportant to locate those individuals who have particular roles and interests that relate tothe various aspects of water management and water quality. This may not always beobvious from formal titles and structures. It has also been noticeable that once anindividual in a field of professional interest – strategic land use planners for example – isaware that others in the same field are engaging in this process, they are more willing tobecome engaged themselves. This suggests that, for the most part, the establishment ofsome kind of relationship and rapport is a precursor for getting feedback. Our inquiry isessentially about perceptions of the CFMP and preceding involvement processes. But allthe indications so far from the feedback we have received suggest that this applies justas much to the content outputs and outcomes of the CFMP development process and itslonger-term implementation.

The intention behind the questionnaire was to help to draw some comparisons acrossthe many different kinds of organisations and people being approached. In addition, weaimed to get at least a minimum of baseline feedback on the current levels of ‘closeness’or distance in the perceived relationship with the Environment Agency. This could be ameans of judging future changes in these relationships.

3.2.2 The Stockbridge Pathfinder

This need to contact, meet and start to build relationships with potential stakeholders issimilar to David Wilkinson’s experience and findings reported in the StockbridgePathfinder as part of the Environment Agency’s Joining Up Project (Wilkinson et al.2005). In 2002 the Environment Agency (Ridings Area), supported by those affected byfloods along the Aire and Calder in 2000, sent out an invitation to a participative event toa wide range of stakeholders. This was aimed particularly at those who were involvedand/or were perceived to have an influence on land use management and planning. Theresponse was very poor and the event never took place. Subsequent enquiries to someof these key stakeholders along the Aire Catchment indicated that there was often astrong interest in flooding and related issues. But, as confirmed in this study (above), thiswas not always obvious from formal titles and structures.

The earlier findings reported from the Stockbridge Pathfinder indicated that:

• ‘flooding is a growing priority for the local authorities and the regional assembly;• there is a lack of connectedness within stakeholder constituencies of interest

along the catchment;• there is a parallel lack of connectedness across stakeholder constituencies of

interest. This also seems to have been the case, to some extent at least, withinindividual local authorities. But the higher profile of flooding risk does seem to beleading to better lateral communication;

• regeneration and the amenity value of water and rivers probably would act as apositive incentive to bring stakeholders together’(Wilkinson et al., 2005).

Both this study and the Stockbridge Pathfinder point to the significance of establishingrelationships with and between key stakeholders as a precursor for engagement andpartnership working.


3.3 Stakeholders’ views and expectations about involvementin the CFMPs

3.3.1 The range of contacts

Stakeholders’ views are more fully reported in Appendix 3. Appendix 4 lists the people weinterviewed and the completed questionnaires received. Appendix 5 is the questionnaireused. The most significant views are reported below. From the point of view of theEnvironment Agency as a whole, this study represents a microcosm of all theengagement and contacts it has with stakeholders. But, from the perception of thestakeholders we have been in contact with, the vast majority of contacts have been at theRidings Area level. Their contacts have included staff and functions beyond flooddefence. They also include some North East regional staff, especially from CorporateAffairs. To stakeholders, these contacts ‘are’ their experience of the Environment Agency.So references below to the ‘Environment Agency’ need to be interpreted in this localisedcontext, especially when read within the Environment Agency itself.

During this study we have used the term stakeholders in a generic and generalisedsense, including national statutory bodies, voluntary/environmental organisations, bothlocal and national, and communities, citizens and residents, including those who havebeen affected by flooding. A significant part of our attention has focused on the statutorybodies, particularly local authorities, as it has become increasingly evident that, togetherwith the Environment Agency, they have key roles to play in mitigating flood risk from allsources of flooding.

(Note: the only statutory consultees for the Environment Agency are Defra, EnglishNature, English Heritage and the Countryside Agency.)

3.3.2 Summary of stakeholder views

• All stakeholders have expressed a strong interest in both the development andlong-term implementation of CFMPs. Broadly, most stakeholders see real value inholistic approaches to catchment and water management.

• For many, holistic approaches require close partnership working with a range ofother agencies to tackle flooding of all types and causes. One respondent saidthat ‘CFMPs must include a description of urban arrangements’ for doing this.Most also have some interest in the issue of water quality. For a few, inregeneration for example, this may be the starting point. The water company seesthe issue of water quantity, flow and quality as interconnected.

• Most stakeholders want clearly established relationships with the EnvironmentAgency throughout the life of CFMPs. These may need to be continuing orintermittent for different stakeholders. They may be wide-ranging or about specificitems and contexts. There is not a single, simple model for all. Most stakeholderswant more than distant ‘consultation’. Establishing appropriate relationships isseen to be key.


• Those stakeholders who are familiar with Making Space for Water – and many are– share the new philosophy of living with water and its holistic approach. But somealso referred to unresolved conflicts between Defra and ODPM action, particularlyin relation to planning.

• However, many stakeholders also question whether the Environment Agency hasa real interest in their water-related priorities or understands sufficiently theirframeworks of governance and regulation.

• Whatever the rhetoric of high-level strategy driving CFMPs, many stakeholderswonder if the Environment Agency is just going through the motions and makecomments such as:

‘Is this just the traditional approach to flood defence in a new guise?’ ‘Has anything changed since the days of the old National Rivers Authority?’ ‘Is the Agency just going through a box-ticking exercise because it has to do

consultation?’ ‘Are they really interested in anything other than main river flooding and hard

defences?’

• In addition to this, however, some suggest that the Environment Agency may be ina difficult position in addressing more holistic agendas because of Defra targets(no loss of life; economic value of property at risk), the old established‘engineering culture’, the absence of clarity from the top down, local communityand short-term pressures, big increases in the budgets available for flooddefences and changes to the funding route and the decision-making process.

• The Environment Agency is often not good at explaining things or the reasons forits decisions. Much of the information is often highly technical and difficult to makesense of and understand.

• Some also saw the Environment Agency as very fragmented and siloed.Comments were made on:

the lack of interdisciplinary working on a catchment basis; all the work on CFMPs being done by contracted engineering consultants,

apart from the consultation; the Environment appearing to be a very top-down organisation and therefore

finding it difficult to relate to the contexts of very different catchments withdifferences in geomorphologies, land use, patterns of settlement, stakeholderand institutional histories and networks, and so on.

3.3.3 Examples of typical stakeholder comments(see Appendix 3 for other comments)

‘Earlier communication/consultation by the Environment Agency would haveprovided a clearer context and understanding of the CFMP process.’

‘Briefing papers need a translation.’

‘Environment Agency staff do not own a participative approach.’


‘Putting a partnership programme together takes time!’

‘If we work together as partners, we can help each other achieve our goals.Working separately, we will only achieve goals in “tick boxes”.’

‘Some people listen well, others don’t – “the wooden face” as I am speaking.Senior people are fine, but others can be more difficult. They [the EnvironmentAgency] are not natural “people”-people.’

‘The Environment Agency should take on board other people’s agendas too.’

‘The Environment Agency is fixed on flood defence. Consultation is only a tick-boxexercise – paying lip-service.’

‘We have usually been asked to comment on things which have taken place,rather than having any direct involvement in the process.’


4 Overcoming barriers toeffectiveness

4.1 Overcoming barriersThe most striking thing coming out of our inquiry into the Environment Agency’s approachto CFMPs and stakeholders’ perceptions of these is the potential for misunderstandingand conflict, rather than the progressive building of common ground.

Environment Agency staff locally – members of the ‘core’ team – have been working hardand systematically to keep a wide range of stakeholders informed about progress and toencourage feedback from them. Nationally, the policy guidance emphasises a holistic,high-level strategic approach to catchment management. This is further reinforced by theDefra policy Making Space for Water with its emphasis on managing flood risk from allsources. Yet there is a widespread perception among many stakeholders that theEnvironment Agency’s actual focus is still on main river flooding and hard defences andthat it does not really understand the stakeholders’ priorities, opportunities andconstraints. This mismatch of perceptions presents the risk of a considerable loss ofopportunities, especially for joint working on agreed policies, strategies and plans andtheir implementation.

This appears to be the main barrier to increasing both the short- and long-termeffectiveness of the CFMP process and implementation as far as the Aire and Calder areconcerned. However, it is a major barrier only if the Environment Agency wants to useCFMPs as a holistic approach to catchment management to tackle flooding from allsources. If the primary focus is on hard defences, then regular and reliable informationgiving and consultation will probably suffice.

On the assumption that the Environment Agency does want to move towards a strategic,holistic approach to CFMPs and embrace the philosophy and approach contained inMaking Space for Water, we would recommend the following for the development ofstakeholder engagement along the Aire and the Calder:

• Further work needs to build on the many good and positive relationships thatalready exist. Typical examples of these are:

community and interagency collaboration, which included the EnvironmentAgency, after the Stockbridge flooding in October 2000;

the recent Bradford Water Management Inquiry and subsequent stakeholderpartnership development;

ongoing work with British Waterways.

• There needs to be a single clear narrative that embraces the changing philosophyand approach towards flood risk and water management as a whole. This couldalso clarify the Environment Agency’s position on working with stakeholders,seeing them as long-term partners in the implementation of agreed CFMPs.


• This narrative would also need to describe how the provision and maintenance ofhard defences on main rivers sits within this.

• Making Space for Water should be the guiding framework for constructing thissingle narrative for the development of CFMPs and gaining joint understandings. Itcould serve to overcome the confusion that appears to exist within theEnvironment Agency about what precisely CFMPs are and how they link toMaking Space for Water and, longer term, to the Water Framework Directive.Without this single narrative, stakeholders are doing their own speculating andthis, as our feedback indicates, is unlikely to benefit the Environment Agency andespecially all those doing the hard work on the ground. Nor will it help withimplementation.

• Such a narrative would also need to be brief – about one or two pages – andpresented in a clear and straightforward to as many stakeholders as possible. Itwould need to overcome the technocratic tendency.

• The approach to stakeholders needs to move from one of information andconsultation about an Environment Agency plan towards one of relationship andpartnership building in which the Environment Agency is taking a lead role indeveloping and implementing a joint plan. This should build from the ‘BuildingTrust’ approach.

• The Environment Agency should meet with its key stakeholders on a catchmentbasis to work participatively with them to develop a shared understanding of whatthe CFMP is, what it is for, who it is for, and how stakeholders (as partners?) willwork on its development and its implementation both together and apart. In otherwords, stakeholders would be engaging in conversations with each other aboutthe kinds of issues that have been raised with us and outlined in this report.

• This dialogue would also focus on the kinds of understandings and relationshipsother stakeholders need with each other. The focus should not be solely onrelationships with the Environment Agency, although this would inevitably be thestarting point.

• The approach would recognise from the outset that the issues and remedies beingdealt with are often complex and difficult. There will be areas where consensus isnot possible, some stakeholders will be disappointed, and some conflict may beinevitable. Common ground, especially about the big picture and specific projects,should be sought wherever possible, but difference and conflict need also to berecognised, made apparent and acknowledged. For example, some communitiesare unlikely ever to get defences or other alleviation measures and will have tofocus on resilience.

• The core proposition on which this approach is based is that strong relationships,formed around shared overall understandings, are far more likely to withstandconflicts and indeed resolve some of those that might otherwise have led to stand-offs and breakdowns in relationships.


• Developing CFMPs and their processes of implementation need to be seen as twosides of the same coin. Given the 50-year plus timescales, CFMPs will need to beupdated in the light of both top down policy and bottom up experience.

• Given this recommended approach, continuation of this study on an actionlearning basis could develop into a demonstration project. It would explore andacquire knowledge about a more integrated approach to developing CFMPs bothwithin the Environment Agency and with its stakeholders.

• Despite the availability of Volumes 1 and 2 of policy and guidance on CFMPs, atthe local operational level there appears to be some uncertainty about what isexpected. For example, it is not clear what the status of the new ‘template CFMP’is. In the absence of clarity, staff have to get on with the work as best they can.There appears to be some hierarchical fragmentation of effort and understandingbetween the area, regional and national levels. This may be blocking the potentialfor bottom-up learning to inform policy and guidance.

• A continuing action learning demonstration project would also seek to overcomethese barriers to organisational learning and dissemination by drawing in a limitednumber of senior staff from time to time to review and reflect on progress and toovercome any barriers to the flow of good information both top down and bottomup.

• We would also strongly recommend that the continuing project serves tostrengthen lateral/horizontal integration of Environment Agency staff on acatchment basis and to encourage more multidisciplinary working. We suspectthat this would be welcomed by many stakeholders, especially those with a focuson water quality and regeneration as well as flood risk management. It would begood if this lateral integration included the engineering consultancies working onthe plans.

• These approaches would need guidance and facilitative support and we feel thatthe quality of participatory events could be improved through this.

4.2 Developing perceptions of the bigger picturePotentially, Making Space for Water and the Water Framework Directive will have asignificant impact on how CFMPs are developed and implemented. They represent theculmination of a changing philosophy in the approach to water management from anindustrial to a post-industrial society and ecology. Given both the speed and scale ofthese changes, together with increasing flood risk linked to climate pattern and land usechanges, it is hardly surprising that there will be different interpretations and perceptionsof what CFMPs are. Our inquiry suggests that these differences exist both within theEnvironment Agency and with external stakeholders. One way of developing sharedunderstandings and achieving common ground, and also clarifying where basicdifferences exist, would be to encourage a cross-section of key people to consider theirindividual responses to a range of questions in facilitated discussions. The questionswould need to be about the ‘bigger picture’ and the longer term. They could be along thefollowing lines:


• What are CFMPs? Who are they for? What are they for? How do they link toMaking Space for Water, the Water Framework Directive, land use planning andregeneration etc? (Initial individual responses to be no more than one side.)

• What is your picture of stakeholders working together in (say) 5/10 years time inrelation to (say):

defences? flooding of all types? water management, flow, quantity and quality? amenity and regeneration?

• What would you like the Environment Agency to do to move towards this?

• What would you like other stakeholders besides the Environment Agency to do tomove towards this?

• What will happen in (say) 5/10 years time if these questions are not addressed?What will the scenario be?

• Can holistic CFMPs be developed and implemented if these kinds of questionsare not addressed and stronger partnerships are not developed?

4.3 Streamlining and speeding up the CFMP processOur inquiry suggests that there is potential for improving, streamlining and speeding upthe CFMP process through early stakeholder engagement and partnership building withstakeholders. This should improve the quality and amount of feedback, as well as spreadownership of the plans. If they become blueprints for whole-catchment stakeholdercollaboration, then this should lead to greatly improved implementation and planupdating.

4.4 River Teign CFMP – Model PlanDuring the study we heard speculation within the Environment Agency that a modeltemplate was being developed to provide further guidance on what a CFMP should looklike. We got sight of a copy late in May 2005. The ‘Model Plan’ is dated February 2005.It provides a number of helpful directions that could inform a simple narrative forcommunicating the core purpose of CFMPs both within the Environment Agency itselfand to stakeholders. The template:

• re-emphasises that a CFMP ‘is a high-level strategic plan through which theEnvironment Agency seeks to work with other key decision makers within a rivercatchment to identify and agree long-term policies for sustainable riskmanagement’ (p. 11);

• connects CFMPs to other land use plans (p. 14 for example) and also to the WaterFramework Directive (p. 15). ‘CFMPs are a learning process to support anintegrated approach to land use planning and management, and also River BasinManagement Plans under the Water Framework Directive (Foreword);


• confirms that CFMPs involve ‘undertaking a high-level strategic assessment ofcurrent and future flood risk from all sources (i.e. rivers, sewers, groundwater etcwithin the catchment …)’ (p. 12, also see Foreword);

• stresses the importance of stakeholder engagement. ‘The Environment Agencycannot achieve a reduction in flood risk across England and Wales alone. It isessential that all key organisations and decision makers in a catchment worktogether to plan and take action in an integrated way to bring about a reduction inflood risk’ (p. 16, also see Foreword).

While apparently embracing the philosophy of Making Space for Water, there is no directreference to it.

The Teign Model Plan lists member organisations of the Steering Group and states that itwas ‘responsible for steering the development of the CFMP and taking key decisionsalong the way’ (p. 16). From the perspective of this study, it would be interesting to knowhow this was done and is continuing, and what stakeholder perceptions are of thisinvolvement process. (The note at the beginning of the document does say that ‘someinformation in the Model CFMP is fictitious’). Given the affirmation of these broadprinciples, together with the importance of stakeholder engagement, this Scoping Studypoints to the vital importance of early relationship building with stakeholders at thecatchment level from the inception of CFMPs.


5 Proposals for the Main StudyThe Main Study would build on the findings of this Scoping Study and the linked socialresearch carried out by the Social Policy Team.4 It would also dovetail into the RidingsArea CFMP timetable (see Appendix 1).

These proposals are presented in outline for further discussion within the EnvironmentAgency. This could be the basis for an agreed detailed specification.

The main aim would be to develop further, and strengthen, the relationships and mutualexpectations between the Environment Agency and significant stakeholders andcommunities in the development and longer-term implementation of CFMPs. It wouldplace these relationships as a central component in the production of robust CFMPs andin building essential partnership working for mitigating future flood risk of all types. Thiswould build from the approach laid out in ‘Building Trust with Communities (EnvironmentAgency, 2004)’.

There would be two linked streams to this work: developing participatory events anddeveloping learning frameworks.

5.1 Developing participatory eventsWe would work alongside the Ridings Area Flood Defence Team and regional CorporateAffairs staff to develop a series of inclusive, participatory events. These would include thePolicy Appraisal Workshops in October and December 2005 for the Calder and Airerespectively. We also suggest that there should be further workshops/events in parallelwith the feedback processes required by the formal guidance in April and May 2006respectively. There would be four elements to supporting these events.

5.1.1 Process

The provision by ourselves of design and facilitation skills for different elements of theseproposals and the integration between them. These different elements are set out in5.1.2, 5.1.3 and 5.1.4 below. Design and facilitation skills would also apply to developingthe learning frameworks set out in 5.2 below.

5.1.2 Context

This element would give support and guidance on the presentation of key informationand would help participants, from their varied backgrounds and contexts, make sense ofthe core components. This support could come variously from the consultant team, otherEnvironment Agency staff, other stakeholders and outside specialists. The ‘language’ ofthe CFMP process can be difficult for ‘outsiders’ to penetrate, including those from otherprofessional backgrounds. Areas of development here include both verbal and visualpresentation of information, concepts, proposals and tools of analysis. There is a need

4 Bailey (2005); Baptiste (2005); Cornell (2005); Speller and Twigger-Ross (2005); Twigger-Ross and Speller (2005a,

2005b); Wade et al. (2005); Walker et al. (2005).


for people to be able to ‘picture and visualise’ how whole rivers and catchments ‘work’through the development of virtual models and plans.

5.1.3 Designing participatory events and activities

We would propose involving a number of representative stakeholders, with EnvironmentAgency staff and ourselves to help guide these processes and advise on continuingstakeholder engagement and involvement. This group might point to the specific need formore specialist, less generic, catchment-based workshops. Examples could focus onstrategic land use planning, drainage, agricultural and moorland land use managementand practices, water as the focus for regeneration and amenity, and so on. Alternatively,this need could flow from the policy appraisal workshops if time and space is built in toallow for stakeholder agendas and expectations.

5.1.4 Leading – presenting the Environment Agency’s CFMP overview

These proposals are also based on the Environment Agency providing a simple narrativeabout flood risk management from all sources of flooding, overall catchmentmanagement, the place of hard defence provision within this, and the role of partnershipworking. This can be provided at area level but it would be particularly valuable if seniornational managers in flood risk, and potentially in water quality, could be involved in thisas event participants from time to time.

5.2 Developing learning frameworksThe purpose of the learning frameworks would be to develop personal and collectivelearning within the Environment Agency through strengthening practice on the ground.This would then serve as a seedbed for developing learning networks, guidance andsupport across the areas, regions and the Environment Agency as a whole. At the core ofthis idea is strengthening the links between thinking and doing, learning and action andpolicy and practice.

There would be four connecting strands to the development of the learning framework.Each would involve a cyclical process of reflection on previous action, clarifyingemerging questions and issues, seeking new information and ideas, planning nextactions, and so on.

5.2.1 Working with a ‘core’ team

We anticipate that this would involve the area Flood Defence Team and members of theregional Corporate Affairs Team. It could also involve others within the organisation at thearea level. It would meet monthly for both full and half days. (These would include themeetings described in 5.2.3 below.)

5.2.2 Working with a wider internal group on a catchment basis

The purpose of this group would be to bring people together from across theEnvironment Agency who have a stake in the development and particularly theimplementation of CFMPs. This could be done on an individual catchment basis or


across the two catchments as a single group and would also involve the core group. Itcould meet for a start-up day and perhaps every two or three months after that for halfdays. This might involve external stakeholders from time to time.

5.2.3 Working with the hierarchical linkages

There would be occasional meetings that would bring together the core team withappropriate senior staff from Flood Risk Management, Water Management, Social Policyand Corporate Affairs. Meetings would be for half a day and focus on reviewing theoverall process and the participatory events. It would be important that the senior staffinvolved had engaged in one or more participatory event.

5.2.4 Developing wider learning networks

These would be designed towards the end of the Main Study and be based on theexperience and learning that had been gained. They would include the following:

• Specific ideas about what the Environment Agency at area level could do, using itsown resources, to spread learning to the Don and Hull CFMPs. These proposalsto be made in December 2005.

• Good Practice guides on stakeholder involvement in the development andimplementation of CFMPs. These would build from ‘Building Trust withCommunities’ and the ‘six-step process’ within this.

• Designing and proposing a regional and national framework for learning and alsothe replication and spread of good practice. This would be based on theEnvironment Agency developing this largely from its own resources. We see thework of the hierarchical linkages (5.2.3) group having a particular contribution tothis.

5.2.5 Overview

Strand 5.2.1 would be a development of the process already started during the ScopingStudy. Strands 5.2.2 and 5.2.3 are specifically designed to address issues of internalfragmentation identified in this report. They are also intended to strengthen the linksbetween action and learning, and between policy and doing (planning andimplementation at the local/catchment level in specific contexts).

Clearly, this would be a fairly extensive piece of work. In the first place, it would needagreement in principle and then in further detail about the main components. This couldthen become the basis for a detailed specification.


ReferencesBailey P, 2005 Observations on Flood Risk Management Policy and Procedures.Environment Agency: Internal report.

Baptiste A, 2005 A Review of the Agency’s Flood Risk Management Appraisal Process.Environment Agency: Internal report.

Barnett J, Breakwell G M, Rootes C, Doherty B and Gray K, 2005 Understanding SpecialInterest Groups: Impacts and Influence. Draft Report on Environment Agency StaffInterviews. Conducted for the Environment Agency by the University of Surrey.

Clark J, Stirling A, Studd K and Burgess J, 2001 Local Outreach. R&D Technical ReportSWCON 204. Bristol: Environment Agency.

Cornell S, 2005 Improving Stakeholder Engagement in Flood Risk Management DecisionMaking and Delivery. Draft science report to the Environment Agency.

Defra 2004 Making Space for Water. Developing a New Government Strategy for Floodand Coastal Erosion Risk Management in England. A Consultation Exercise. London:Stationary Office.

Defra and the Environment Agency 2004 Volume 1: Policy Guidance on CFMPs. Bristol:Environment Agency.

Defra and the Environment Agency 2005 Volume 2: Policy Guidance on CFMPs. Bristol:Environment Agency.

Downs S E J, 1997 A Methodology for Community Involvement in LEAPs. R&D TechnicalReport W32. Bristol: Environment Agency.

Environment Agency 1998 Consensus-Building for Sustainable Development. SD12.Bristol: Environment Agency.

Environment Agency 2003 Guidelines for Planning and Managing NationalConsultations. Working draft status, April 2003.

Environment Agency 2004 Building Trust with Communities: A Toolkit for Staff. Publishedon the Environment Agency internal website.

Orr P and Pound D, 2005 Presentation to the CIWEM Conference: Participation and theEnvironment: Working With People to Achieve More Sustainable Solutions. London:SOAS, 8 March.

Petts J and Leach B, 2000 Evaluating Methods for Public Participation: LiteratureReview. R&D Technical Report E2-030. Bristol: Environment Agency.

Porter S, Warburton D and Wilkinson D, 2005 Joining Up: Thames Pathfinder. ScienceReport E2-057/SR7. Bristol: Environment Agency.


River Teign Catchment Flood Management Plan. Model Plan. Defra, the EnvironmentAgency, Welsh Assembly Government. February 2005.

Speller G and Twigger-Ross C, 2005 Improving Community and Citizen Engagement inFlood Risk Management Decision Making, Delivery and Flood Response. ScienceReport SC040033/SR3. Bristol: Environment Agency.

Twigger-Ross C L and Smith C-R, 2000 Public Involvement in Agency Activities. NationalCentre for Risk & Options Appraisal Report. Bristol: Environment Agency.

Twigger-Ross C and Speller G, 2005a Understanding the Social Impacts of Flooding onUrban and Rural Communities. Science Report SC040033/SR1. Bristol: EnvironmentAgency.

Twigger-Ross C and Speller G, 2005b Improving the Contribution of Social Science to theFlood Risk Management Science Programme. Science Report SC040033/SR4. Bristol:Environment Agency.

Wade S et al., 2005 Guidance note 2: Community engagement and sustainabledevelopment. In Sustainable Flood and Coastal Management: Final Draft TechnicalReport, Part 1: Handbook (Revision 1.0, March 2005). Defra/Environment Agency R&DDraft Technical Report FD2015.

Walker G, Burningham K, Fielding J, Smith G, Thrush D and Fay H, 2005 AddressingEnvironmental Inequalities: Flood Risk. Science Report SC020061/SR1. Bristol:Environment Agency.

Warburton D, 2004 Understanding the Agency’s Role in Local Communities. Report tothe Joining Up project board. Bristol: Environment Agency.

Warburton D, Levett R and Pilling A, 2005 Understanding the Social Context of theAgency’s Work – Policy and Literature Review. Science Report E2-057/SR1. Bristol:Environment Agency.

Wilkinson D, Warburton D, Porter S and Colvin J, 2005 Joining Up: StockbridgePathfinder. Science Report E2-057/SR4. Bristol: Environment Agency.


Appendix 1. North East, RidingsCFMPs timetableIt is planned to develop four CFMPs. Individual timetables are as follows:

1. Calder CFMP

When Milestone Output

May 2003 Calder CFMP starts

May 2004 CFMP Inception Workshop Inception Report Engagement with

stakeholders

March 2005 CFMP Scoping Report Broad-scale model for theCalder

Assessment of catchmentissues

Opportunities andconstraints identified

Draft appraisal objectives Draft scenarios

July 2005 End of CFMP ScopingConsultation

Statutory consultationfeedback

Direction for Main Stage

October 2005 Policy Appraisal Workshop Joint decision making ondraft policies

January 2006 Draft CFMP Report Draft catchment policies Formal consultation

April 2006 End of Draft CFMPConsultation


June 2006 Final CFMP Sustainable catchmentpolicies

Strategies and studiesidentified where needed


2. Aire CFMP

When Milestone Output

February 2004 Aire CFMP starts

October 2004 CFMP Inception Inception Report Initial engagement with

stakeholders

April 2005 Scoping Workshop Draft catchment appraisalobjectives and opportunitiesand constraints

July 2005 CFMP Scoping Report Broad-scale model for theAire

Assessment of catchmentissues

Opportunities andconstraints identified

Draft appraisal objectives Draft scenarios

October 2005 End of CFMP ScopingConsultation


Direction for Main Stage

December 2005 Policy Appraisal Workshop Joint decision making ondraft policies

February 2006 Draft CFMP Report Draft catchment policies Formal consultation

May 2006 End of Draft CFMPConsultation


July 2006 Final CFMP Sustainable catchmentpolicies

Strategies and studiesidentified where needed

3. Don CFMPExpected programme dates are from January 2006 to December 2007.

4. Hull CFMPExpected programme dates are from March 2006 to April 2008.

Appendix 2. CFMP Regional Steering Group (Yorks andHumber) June 2005Organisation and title Contact and relevant

CFMPsPostal address Email Telephone

numberYorkshire WaterSewerage OptimisationManager

Trevor Birch Western HouseHalifax RoadBradfordWest Yorkshire BD6 2SZ

[email protected] 01274 600111(switchboard)

British Waterways Rob Arrowsmith Fearns WharfNeptune StLeeds LS9 8PB

[email protected]

0113 2816800

National Farmers’ UnionEnvironment and Land UseAdviser

Laurie Norris NFU North East and North West RegionsAgriculture House207 Tadcaster RoadYork YO24 1UD

[email protected] 01904 451567

The RSPBRegional Policy Advocate

Nicola Melville 7 Whitehouse RiseYork YO24 1EE


Countryside Agency Stuart Pasley 2nd Floor, Victoria WharfeEmbankment IVSovereign StLeeds LS1 4BA


English Heritage – regionalofficeRegional Land Use Planner

Ian Smith 37 Tanner RoadYork YO1 6WP


English Nature Deputy TeamManager

BernieFleming

CalderAireDon/Rother

Humber to Pennines TeamBullring HouseNorthgateWakefield WF1 3BJ

01924 334500

English Nature Deputy AreaManager

SarahWoolven

DerwentEsk andCoastOuse

Genesis 1, University RoadHeslingtonYork YO10 5ZQ

01904 435500

The Yorkshire and HumberAssembly

Will Kemp 18 King StreetWakefield WF1 2SQ



Organisation and title Contact and relevantCFMPs

Postal address Email Telephonenumber

Yorkshire Forward Debbie Rosen The Environment and DevelopmentDirectorateYorkshire ForwardVictoria House2 Victoria PlaceLeeds LS11 5AE

[email protected]

0113 3949783

Country Land and BusinessAssociationRegional Director

Dorothy Fairburn Regional Office – Yorkshire/HumberOld Toll BoothMarket PlaceEasingwoldYork YO61 3AB


Forestry Commission Vince Carter Yorkshire and The Humber ConservancyWheldrake LaneCrockey HillYork YO19 4FF


City of Bradford MetropolitanCouncilSenior Policy Officer (Health,Environment and RuralTeam)

Dave Melling Department of Policy and ExecutiveSupport4th Floor, Jacobs WellBradfordWest Yorkshire BD1 5RW


North York Moors NationalPark AuthorityNational Park Officer

Chris de Silva The Old VicarageBondgateHelmsleyYork YO62 5BP

[email protected]

01439 770657

Defra Flood and CoastalManagementRegional Engineer

Jim Hutchison Regional Engineers OfficeFoss HouseKings Pool1–2 Peasholme GreenYork YO1 7PX


Environment AgencyRegional ProgrammeManager

Bill Rodham Rivers House21 Park Square SouthLeeds LS1 2QG

[email protected]

0113 2312359

Environment AgencyDerwent CFMP ProjectManager

Vicky Spencer Coverdale HouseAmy Johnson WayClifton MoorYork YO30 4UZ

[email protected]

01904 822571


Organisation and title Contact and relevantCFMPs

Postal address Email Telephonenumber

Environment AgencyEsk and Coast CFMP ProjectManager

Rebecca Chapman Coverdale HouseAmy Johnson WayClifton MoorYork YO30 4UZ

[email protected]

01904 822588

Environment AgencyAire and Calder CFMPsProject Manager

Sophie Vanicat Phoenix HouseGlobal AvenueLeeds LS11 8PG

[email protected]

0113 2134869

Environment AgencyTyne and Wear CFMPsProject Manager

Mary Taylor Tyneside HouseSkinnerburn RoadNewcastle Business ParkNewcastle upon Tyne NE4 7AR

[email protected]

0191 2034329

Environment AgencyEnvironmental AssessmentOfficer

Jo Murphy Phoenix HouseGlobal AvenueLeeds LS11 8PG

[email protected]

0118 9535540

Environment AgencyRegional Flood DefenceManager

Mark Tinnion Rivers House21 Park Square SouthLeeds LS1 2QG

[email protected]

0113 2312458

Appendix 3. Stakeholder feedbackQuestion 1

Only 25% said that they had a good/very good level of knowledge of CFMPs.

What level of knowledge do you already have of the CFMP?

0123456789

None Poor Moderate All right Good V Good

Question 1(c)

70% said that communication could be improved.

Could the communication of this CFMP be improved?

70%

30%

YESNO


Question 2

Wide range of responses here. 25% said ‘Good’, but 30% said ‘None’.

How would you assess the Environment Agency's communications about the CFMP with

you so far?

None30%

Poor15%

Moderate5%

All right25%

Good 25%

V Good0% None

PoorModerateAll rightGood V Good

Additional information is included below on aspects of communication.

Question 2(a)

If you have scored below 3 on Question 2, could you please explain what problemsthere are with the communications from the Environment Agency?

This is a summary of those answers, with some specific quotes:

Several people answered that the communication had been non-existent.

There is an assumption that people will know what a ‘catchment’ is! (What does this wordmean to a person who is not a rivers specialist?)

‘We have usually been asked to comment on things which have taken place, rather thanhaving any direct involvement in the process.’

‘They are not willing to listen – except one person on the Regional Steering Group –whom I always phone now.’

‘Earlier communication/consultation by the Environment Agency would have provided aclearer context and understanding of the CFMP process.’

‘The work appears to be an internal Environment Agency plan. It is not clear that theconsultants on the Wharfe understand what is going on. Potential partners are not awareof how they could collaborate on the plans.’


Question 3

45% said ‘Good’, but 35% said that this willingness to listen was non-existent.

How would you assess the Environment Agency's willingness to listen to your ideas and

experience?

Non-existent35%Good

45%

Feel included0%

Moderate5%

Poor10%

V Good5%

Non-existentPoorModerateGoodV GoodFeel included

Question 4

Widely diverse range of responses here. 25% said ‘Not at all’, 25% said ‘Adequately’ and15% said ‘Very Well’.

How much do you think the Environment Agency understands the things you want to achieve?

Not at all25%

V Little15%

Moderately20%

Adequately25%

V Well15%

Completely0%

Not at allV LittleModeratelyAdequatelyV WellCompletely

Question 5

Where does your experience come from in dealing with the Environment Agency?

See attached list of stakeholders (Appendix 4) who were interviewed or who completed aquestionnaire – these included a cross-section of stakeholders, ranging from people whowere flooded in their homes to local authority planners, drainage engineers, RegionalSteering Group members, councillors, and British Waterways Board.


Question 6

What do you wish to be consulted on?

A clear majority of 80% answered that they wish to be consulted on all three stages:Inception Report, Scoping Stage and Draft Plan.

3 people said that they wish to be consulted on the Scoping Stage and Draft Plan.

1 person said they wish to be consulted on the Draft Plan only.

Additional comments on the ‘any other aspect’ were:

‘To be kept up-to-date on everything’

‘Integration and partnership-working potential’.

Question 7

To what extent do you want to be consulted and involved in the development ofCFMPs?

Not at all

Receive information

Provide feedback and influence

Feel fully engaged

Feel a partner in development of plan

Feel partner in development and implementation

0123456789

Not

at a

ll

Rec

eive

info

rmat

ion

Pro

vide

feed

back

and

influ

ence

Feel

fully

enga

ged

Feel

a p

artn

erin

dev

elop

men

tof

pla

n

Feel

par

tner

inde

velo

pmen

tan

dim

plem

enta

tion

A clear majority of the stakeholders in the CFMP wanted ‘to feel a partner in thedevelopment and long-term implementation of the plan’.


Question 7 (Comments)

‘The plans will not work if Local Authorities are not engaged as partners in thedevelopment and long-term implementation of the plans.’

Comment at Question 7 from British Waterways:‘As a statutory navigation authority, British Waterways would hope to be involved in anylong-term partnerships, which will provide agreed environmental, economic and socialbenefits in each local area. Broader and more permanent partnerships with localauthorities and other public bodies, such as the Agency and the Regional DevelopmentAgencies, would enable the local and regional benefits of the waterway network to betailored to local needs and maximised’.

(From Councillor) ‘I am given feedback from residents that, at the moment, I cannotcommunicate to the EA because there are no channels. They send out their PR peopleto flooding incidents – but no-one really listens – it is just a PR exercise.’

‘As the plans have a long-term impact on flood alleviation which affects NFF [NationalFlood Forum] constituents on a long-term grass-roots level, we need to be well informedof plans.’

Question 8 (Comments)

Please comment on the type of involvement you would currently prefer:

‘Participation in development and implementation – not consultation!’

‘To be provided with draft proposals and attend meetings to comment.’

‘I would like to be kept informed of the various stages in the CFMPs’ development andgiven the opportunity to comment, if necessary.’

‘To be considered as a relevant consultee at each stage of the process.’

Comment from British Waterways:‘British Waterways has unrivalled expertise in the management, enhancement andconservation of navigation on inland waterways, with a strong team of civil engineers,hydrologists and environmental managers. We would hope to take the lead in consultingand co-ordinating with the other UK navigation authorities to offer the benefit of ourexpertise in seeking out rationalised policies and systems of operation, as far aspossible, for the good of Britain’s inland waterways and their users.’

‘Local meetings/consultation on a face-to-face basis. Locally appointed EArepresentative who is contactable’

‘Workshops, emails and posted material’


Question 9

What channels of communication would you prefer?

40% answered that they wanted all four types of communication, i.e. plain Englishcommunications by post or email, opportunities to provide feedback to the EnvironmentAgency, face-to-face meetings within stakeholder groups along the catchment, andparticipative stakeholder events, with as wide a mix of stakeholders as possible.

Question 10

What method(s) of consultation do you consider to be most effective?

95% answered ‘face-to-face meetings’ in one form or another.

Other answers included:

• Stakeholder events

• Workshops on specific issues

• Face-to-face consultation, with feedback on how information has been factored (ornot) into the plans.

• Meeting face-to-face with a stakeholder group, so that stakeholders can share theirviews and have impact on the ultimate outcome.

• Key stakeholder meetings to discuss specific issues.

• An individual from the Environment Agency is at a meeting (e.g. at a NeighbourhoodForum) where people can ask their own questions and give their personal viewsdirectly to the Environment Agency.

• Participative – with joint action planning. Use of visioning exercises, SWAT and othermanagement thinking tools.

Question 11

Which of these methods of providing information to you do you consider to bemost helpful?

CDsSummary ReportFull ReportWebsite

15% of people said all four methods.

45% answered the Summary Report and the Full Report.


25% only answered that the CDs or the website was helpful.

5% said the CD ‘for mapped information only’

Additional comments were:

‘The website is not very good – the order of it is not effective, and not everyone hasInternet access.’

Question 12

Through the Catchment Flood Management Planning process, in what way do youthink the Environment Agency could contribute to helping you/your organisationwork towards your longer-term priorities and goals?

Examples of comments made here are as follows:

‘If we work together as partners, we can help each other achieve our goals. Workingseparately, we will only achieve goals in “tick boxes”.’

‘Work in partnership to plan for and achieve sustainable development throughout theplan area in terms of flooding and flood risk.’

‘Through appreciating the regeneration and development needs of town centre, brown-field sites that are often located within flood zones 2 and 3a.’

‘By continuous reporting back of proposals and decisions on both riverine and landdrainage.’

‘Local consultation with Parish Councils, and regular updates to be provided to them.’

‘To encourage community involvement in sustainable development.’

‘Bradford is developing a Water Management Policy which, if it is to be effective, needsto be informed of things outside its area and control.’

‘In including biodiversity conservation targets/actions in the planning.’

‘By identifying new sustainable areas that can be defended and taking these projectsforward.’

‘By influencing the planning and design of new developments to mitigate againstflooding.’

‘It is most valuable in terms of assisting our forward planning policy efforts (LocalDevelopment Framework).’


Question 13

Do you want to continue to be involved in the CFMP process?

100% of stakeholders answered YES to this question.

Examples of comments added at Question 13 are as follows:

‘Regarding the CFMP process so far – it is confusing! We met with the consultants doingthe Wharfe plan 2 years ago – no feedback to date! The CFMP process for the Aire is notclear; there are no links to other strategies, e.g. the Regional Economic Strategy,regeneration strategies, Sustainable Food and Farming Strategy, etc.’

‘The EA needs to be more proactive (rather than reactive) by engaging at ground andlocal level – not national level.’

‘How does this relate to River Basin planning, etc? To what extent is the RegionalDevelopment Agency engaged – if at all?’

‘One major concern is that, although there is a general acceptance that long-termplanning of sustainable flood alleviation and management is the way forward, there is ananxiety that this is not taking into consideration the views of those at direct risk who arelooking for more immediate solutions to having their homes flooded. Perhaps some moreproactive PR is needed to sell CFMPs to the general public, along with promotion ofshorter-term resilience measures.’

‘I can offer support/assistance from a land use planning perspective.’


Question 14

How much do you think the Environment Agency understands the things that youwant to achieve for the river, the river catchment, water management andenvironmental improvements, etc, in your general dealings with them?

How much do you think the Environment Agency understands the things that you want to achieve for the

river, etc?

Not at all0%

V Little20%

Moderately35%

Adequately20%

V Well25%

Completely0%


Question 15

In general, outside of this work with CFMPs, how much do you think theEnvironment Agency seeks to understand and take on board your views andknowledge?

Outside of the work of CFMPs, how much does the EA understand/take on board your views and knowledge?

Not at all15%

V Little10%

Moderately35%

Adequately20%

V Well20%

Completely0%


Appendix 4. Aire and Calder CFMPs– list of people consultedName Organisation Method Questionnaire

returnedTony Poole Land Drainage, Bradford Council Face to face YesDave Melling Policy Development Service, Bradford Council Face to face YesPeter Gooding Wakefield MDC Email YesDavid Fullwood Airedale Drainage Commissioners – Airedale

Internal Drainage BoardsEmail Yes

Delphine Pouget West Yorkshire Ecology, Leeds Email YesGlen Miller Councillor, plus represents Bingley Voluntary

Action GroupTelephoneinterview

Yes

Di Keal National Flood Forum Email YesRuth Parker Planning Officer, Planning Policy, Craven District

CouncilEmail Yes

Angela Cowen Economic Development, East Riding of YorkshireCouncil

Email Yes

Suzanne Jevons East Riding of Yorkshire Council Email NoAndy Haigh Strategic Planning, Yorks and Humberside

Regional AssemblyTelephoneinterview

No

Professor RichardAshley

Professor in Urban Water, University of Sheffield Face to face No

Riley South Shire Group of IDBs Email YesVictoria Megson British Waterways Board Email YesMike Watts Flood Warden, Todmorden Telephone request

and email (plusreminder)

No

Mike Powell Emergency Planning Officer, Bradford Council Telephone andemail

No

Helen White Emergency Planning Officer, North YorkshireCounty Council

Telephone requestand email

No

Lindsey Quinn Craven Flooding Panel, Craven District Council Face-to-facerequest plusreminder

No

Laurie Norris National Farmers’ Union Email NoRobin Coughlan Planning Policy Manager, Leeds City Council Email YesWill Kemp Yorkshire and Humberside Regional Assembly Face-to-face YesMichael Osborne Arups – Lead Partner in Airedale Corridor Plan Face-to-face and

telephoneNo

Terry Heselton Selby District Council Email NoBrian Lavelle Yorkshire Wildlife Trust Email NoPeter Gooding Wakefield Metropolitan District Council, Housing

and Regeneration ServicesEmail Yes

Tony Harrington Head of Environment, Health and Safety forYorkshire Water

Telephone Yes

Susan Wagstaff Consultant Engineer, Jeremy Benn Associates Face-to-face NoSteve Edwards Atkins Water Face-to-face NoAndrew Marshall Strategic Planning, Bradford Council Telephone NoJohn Colvin and hisSocial Policy Team(Paula Orr, AlisonBaptiste, PeteBailey)

Environment Agency Face-to-facemeeting

No


Name Organisation Method Questionnairereturned

John Colvin’smeeting on 14 April2005 (Paula Orr,Stephen Worrall,Carl Jeans, SueReid)

Environment Agency Face-to-facemeeting

No

Stephen Worrall Flood Defence Policy, Environment Agency Telephone NoDorothy Fairburn Country Land and Business Association Face-to-face NoLinda Aucott Defra TelephoneAndrew Abbott Stockbridge Neighbourhood Development Group Face-to-face YesEnid Coleman Stockbridge Neighbourhood Development Group Face-to-face YesDavid Burridge Stockbridge Neighbourhood Development Group Face-to-face YesAlan Parkes Wakefield MDC, Regeneration Email and

telephoneNo

Graham Coultish National Farmers’ Union Email NoJohn Hobson National Farmers’ Union Face to face NoVicky Spencer Derwent CFMP Follow-up for

telephoneNo

Joe Howe Manchester University, Flood ResearchConsortium

Follow-up fortelephone

No

Alan Kendall Wakefield MDC, Land Use Strategy Team Email NoMartin Elliot Leeds City Council, Strategy and Policy

DevelopmentEmail No

Cllr AndrewMallinson

Member of Yorks and Humberside Flood DefenceCommittee

Follow-up for faceto face andquestionnaire

No

Peter Davis Wakefield MDC Email NoDavid Sellers Leeds City Council, Land Drainage Email NoBernard Fleming English Nature, Humber to Pennines Team,

WakefieldEmail No

Ian Smith English Heritage, York – Regional Land UsePlanner

Email No

Mike Hurford Calderdale Council, Strategic Planning Email NoLes Reason Kirklees Council, Strategic Planning Email YesDavid Turner Calderdale Council, Land Drainage Email NoIan Boocock Kirklees Council, Land Drainage Email NoAndrew Quarrie Flood-affected person – Bingley By post YesJenny Sampson Flood-affected person – Bingley By post NoHoward England Flood-affected person – Bingley By post NoPaul Maxwell Flood-affected person – Bingley By post NoJean Robinson Embsay Parish Council Face-to-face

interviewYes

Howard Wadsworth Gowdall Parish Council By post NoR Michelson Kellington Parish Council By post NoSafraz Qureshi Flood-affected person – Stockbridge By post No

Appendix 5. The questionnaireYour involvement with the Environment Agency’sCatchment Flood Management Plans (CFMPs)We are working with the Environment Agency on involving people in the development of CFMPs for the Rivers Aire and Calder. We aim toexplore how the Environment Agency has worked with people so far, and how it can develop its working with any other people who have aninterest in this planning process. These questions are designed to enable you to explore your own experiences, expectations and hopes forCFMPs from the perspective of your own organisation or your specific interest in these rivers.

1. What level of knowledge and understanding do you already have of the CFMP? (Please circle appropriate number n the line below to indicateyour level )

1(a) Where does this knowledge about CFMPs come from? ……………………………………………………………………………………………….

Further comments…………………………………………………………………………………………………………………………………….……….

1(b) How did you acquire this information? ……………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………………………………………….……

1(c) Could the communication of this be improved? YES/NO (Please delete as appropriate)

If YES, please describe how:

……………………………………………………………………………………………………………………………………………………………………….

0 1 2 3 4 5

None Poor Moderate All right Good Very Good


2. If you have already received communications from the Environment Agency, how would you assess the Environment Agency’scommunications about the CFMP with you so far? (Please circle the number at appropriate point on the line below)

2(a) If you have scored below 3 on the scale above, could you please explain what problems there are with the communications from theEnvironment Agency:

…………………………………………………………………………………………………………………………………………………………………

…………………………………………………………………………………………………………………………………………………………………

3. How would you assess the Environment Agency’s willingness to listen to your ideas and experience during the CFMP process so far?

4. How much do you think the Environment Agency understands the things you want to achieve for the river, the river catchment, watermanagement and environmental improvements etc in drawing up CFMPs?

0 1 2 3 4 5 None Poor Moderate All right Good Very Good

0 1 2 3 4 5

Non- Poor Moderate Good Very good I feel hopefullyexistent included

0 1 2 3 4 5

Not at all Very little Moderately Adequately Very well Completely


5. Where does your experience come from in dealing with the Environment Agency? …………………………………………………………….

…………………………………………………………………………………………………………………………………………………….

……………………………………………………………………………………………………………………………………………………

6. What do you wish to be consulted on? Please tick boxes below for any of the stages you wish to be consulted on:

Initial understanding and data collection (INCEPTION REPORT)Review existing policies, understand existing flood risks and identify draft objectives (SCOPING STAGE)Identify policy options and select preferred policies, complete future scenarios (DRAFT PLAN)ANY OTHER ASPECT?

7. To what extent do you want to be consulted and involved in the development of CFMPs?

Please add comments ……………………………………………………………………………………………………...................…………………...

……………………………………………………………………………………………………………………………………………………………….....

8. Please comment on the type of involvement you would currently prefer.

……………………………………………………………………………………………………………………………………………………………………

……………………………………………………………………………………………………………………………………………………………………

1 2 3 4 5

Not atall

To receiveinformation

To providefeedback and toinfluence

To feelfullyengaged

To feel a partnerin thedevelopment ofthe plan

To feel a partner inthe developmentand long-termimplementation ofthe plan


9. What kind of channels of communication would you prefer? (Please tick any of the appropriate boxes below)

o Plain English communications by post/emailo Opportunities to provide feedback to the Agency by post/telephone/emailo Occasional face-to-face meetings within stakeholder groups along the catchment, e.g.

could be specialist meetings with flood-affected people, land drainage engineers,Internal Drainage Boards (IDBs), strategic planners, regeneration officers, environment groups,farmers, landowners, etc.

o Participative stakeholder events bringing as wide a mix of stakeholders as possible together

10. What method(s) of consultation do you consider to be most effective? …………………………………………………………………….…………

…………………………………………………………………………………………………………………………………………………………….……..

…………………………………..……………………………………………………………………………………………………………………………………

11. Which of these methods of providing information to you do you consider to be most helpful? (Please tick the appropriate box):

CDsSummary ReportFull ReportWebsite

12. Through the CFMP process, in what way do you think the Environment Agency could contribute to helping you/your organisation worktowards your longer-term priorities and goals?

Comments

……………………………………………………………………………………………………………………………………………………………………

………………………………………………………………………………………………………………………………………………………….……..…


13. Do you want to continue to be involved in the Catchment Flood Management Planning process? YES/NO (Please delete as appropriate)

If YES, please comment on how you view either of the following as options for the continuing development of your involvement on a

catchment-wide basis after the CFMPs have been completed?

o To work on implementation of CFMPs and their continuing updating

…………………………………………………………………..……………………………………………………………………………………………

o To work between all the different people who have an interest in producing sustainable solutions to water management and relatedproblems and issues.

……………………………………………………………………………………………………………………………………………………………….………

Please add any further comments or information about your views on the Catchment Flood Management Planning process which has takenplace so far: ……………………………………………………………………………………………………………………………………………………….

……………………………………………………………………………………………………………………………………………………………………….

…………………………………………………………………………………………………………………………………………………………………..…..

14. How much do you think the Environment Agency understands the things you want to achieve for the river, the river catchment, watermanagement and environmental improvements etc in your general dealings with them?

Please add comments …………………………………………….………………………………………………………………………….................

……………………………………………………………………………………………………………………………………………………………….

0 1 2 3 4 5

Not at all Very little Moderately Adequately Very well Completely


15. In general, outside of this work with CFMPs, how much do you think the Environment Agency seeks to understand and take on board yourviews and knowledge?

Please add comments ……………………………………………………………………………………………………………………................

……………………………………………………………………………………………………………………………………………………………….

……………………………………………………………………………………………………………………………………………………………….

16. Do you think that there are other people whom we should involve in this consultation process? YES/NO (Please delete as appropriate)

If YES, please provide below the names and contact details for those people:

………………………………………………………………………………………………………………………………………………………………………..

……………………………………………………………………………………………………………………………………………………………………….

……………………………………………………………………………………………………………………………………………………………………….

NAME OF YOUR ORGANISATION ……………………………………………………………………………………………………………………………

YOUR NAME ……………………………………………………………………..DATE………………………………………………………………………..

SIGNATURE ………………………………………………………………………………

We would like to thank you for taking the time to complete this questionnaire.

Whole Systems DevelopmentMarch 2005

0 1 2 3 4 5 Not at all Very little Moderately Adequately Very well Completely

We welcome views from our users, stakeholders and the public, includingcomments about the content and presentation of this report. If you are happywith our service, please tell us about it. It helps us to identify good practice andrewards our staff. If you are unhappy with our service, please let us know howwe can improve it.

Publication Code: SCHO0905BJQT-E-P Contact Olivia Giraud

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